The following notice describes the collection and further processing of personal data by www.azzafahmy.com website and relating customer services.
This notice is addressed to all users of our website (data subjects). Access to any of our services on the website is strictly limited to persons aged at least 18 years.
1- Who we are, who will process your data, data controller and relevant contacts:
www.azzafahmy.com and the on-line shop it represents is jointly operated by Azza Fahmy- Jewellery of Egypt (no. 5272) and its wholly owned subsidiary Azza Fahmy limited (a company incorporated and registered in England and Wales with company number 07675630 whose registered office is at 120 Baker Street, 3rd Floor, C/O Coddan Cpm Ltd, London, W1U 6TU), together designated by “Azza Fahmy group”.
However, Azza Fahmy-Jewellery of Egypt is the controller (the “Controller”) of the website www.azzafahmy.com pursuant to Regulation (EU) 2016/679 on General Data Protection Regulation (GDPR regulation). It is the entity responsible for processing your data, for ensuring that it is securely detained, to respond to your enquiries relating to data processing and to collect and comply with your demands with respect to your rights over your personal data, in compliance with the laws, including GDPR regulation when applicable.
The Controller may be assisted by its abovementioned subsidiary in UK Azza Fahmy Limited, and it currently recourses to the services of a web developer and a hosting server both located in the EU and hence bound by Regulation (EU) 2016/679. Usual security measures are taken so that these third parties have strictly necessary and limited access to the personal data collected on the website.
We may further retain the services of other external suppliers or other technical assistance to help us with collection or processing of personal data, some of which can be based outside EU countries. This will be made under the strict instructions and supervision of the Controller which will make sure to secure data subjects with the same privacy rights guaranteed by law and by the current Privacy Notice, by way of contractual provisions and security measures.
Transfer of your personal data to non-EU countries for processing purposes or for eventual external technical assistance as described above, will be carried out in compliance with the guarantees provided by law, and in strict security and necessity.
Any enquiry or claim regarding your personal data processing can be addressed at the following contact points:
2- What data will be collected, how it will be processed, for how long and for what Purpose:
We collect personal data from when you visit our website, if you subscribe to any of our available services such as marketing alerts and communications, when you communicate with us through website or any other mean, and when you place a purchase order.
2.1 Data you provide us
We collect and process information that you provide us including but not limited to your name, contacts, shipping and billing addresses as requested at every step of the process when creating your account or subscribing to any of the services we offer including placing an order.
This data will be processed for the following purposes:
i) Processing and performing purchase orders and related after-sale services
The data requested when you place a purchase order will be processed strictly in relation to that order fulfilment and the subsequent contract execution, including order confirmation or rejection, order rectification or completion, payment process including related anti-fraud relevant checks, billing, shipping and delivery of the product and handling of eventual returns and complains and any other after-sale service.
ii) Marketing communication and material on an opt-in basis
Marketing communication and materials in connection with our products and services may be addressed to you using the data you provided us. You will be subject to such communication only on an opt-in basis with your prior consent to such, by way of:
- when you create an account, you can elect to sign in or agree to receive different communication materials proposed;
- within the contractual engagement when placing an order you may be requested to opt-in to different communication materials we offer;
- whenever you subscribe to a mailing-list or any other listing for communication materials.
Any consent given for one or more of our marketing related services will be considered valid for a period of 10 years from obtaining such consent.
Marketing communications will be addressed through e-mails, phone messages and eventually geographical address, whenever this information is given by you.
You can at any time withdraw your consent by deregistration, subscription or opting-out from such marketing related services:
- by using the link on the bottom of e-mails;
- by following the corresponding options on our website;
- by contacting us at email@example.com
2.2 Data we collect otherwise
We also collect and process other data that you don’t provide us, which is related to the way you visit and browse our website, including through cookies and similar technics (described further ahead), for the legitimate purpose of ensuring proper usage of our website and for tailoring and optimizing our marketing communication.
Data is collected through our website or whenever an App version of our website is available, we will collect data regarding your use of the App and your IP address, and it includes but is not limited to the IP address and other identification such as but not limited to user name on a social media or related to an e-mail account, smartphones identifiers, computer cookies, referring websites, etc. (see cookies section hereunder)
This could include data about how you came to the website, dates and times of your visits, products you view or search for and in which chronology, download errors, length of visits to certain pages, page interaction data, purchase and other services history and methods used to browse away from the page. This data is collected especially when you create an account on our site or when you subscribe for any of our services but also when you visit our web site.
Such data processing is governed by the related provision stated above according to whether the data is processed within a contractual relationship or as part of our marketing communication strategy, and to specific cookies and similar tools policy described hereunder.
2.3 Cookies, analytics and social plug-ins
We use Internet or Web ‘cookies’ on our Website, which are messages containing information about your visit to our Website and any other information that you have voluntarily provided us, that our webserver passes to your web browser which will store it in files and pass it back to our server each time you re-visit our page.
In that respect, we use session cookies that are only temporarily saved and will be automatically erased when you close your Web browser, to allow session identification, and we use persistent cookies that are stored on your hard drive until it expires or until you delete these which collect identifying information and your web surfing behaviour on our website to optimize your visits and the services we can offer you and allow for an automated log-in.
We recourse to first-party cookies that belongs to our website domain under our controller’s supervision, but also to third-party cookies.
Third party cookies are placed when we place advertisement of third parties on our website – such as banners – or when we place our own advertising on a third-party website. These cookies allow to recognize users and track their web pattern on the respective sites for the sake of personalizing and hence optimizing use of advertisement.
We may use tools like Google Analytics or similar service providers on our Website which use permanent cookies to analyse your browsing behaviour on our website, such service providers may and are often located in non-EU countries (the U.S. for Google).
These cookies may be employed by us but also from their part, in such case, such third-party service providers usually will monitor your use of many other Websites engaged with their services and combine such data and use the findings for its own benefits, like control of advertisement. Note that usage made by a Third party to such cookies will be on the third party’s own responsibility and according to its own data protection policy. We however engage not to disclose any personal data to such third-party service provider.
Cookies usage cannot be made against your will, as follows:
Our usage of cookies will be indicated by one or several banner(s) placed on our Website which will collect your consent by a click.
ii) Withdrawal of consent or cookies deactivation:
You have the right at any time to delete cookies stored on your devise or to block application of cookies. Access to such is from your devise in control cookie settings of your browser (allows you can consult your browser's help files, and search for “archived cookies, and clear web browser from cache cookies and history), usually placed within the "Privacy" or "Security" tabs.
Kindly note however, that blocking or deleting cookies may reduce efficiency of your visit on our website or also limit access to some of the services offered therein.
You may disactivate other e-mail pattern tracking applications in your e-mail application.
For any further enquiry on our usage of cookies kindly contact firstname.lastname@example.org
2.4 Plug-ins from social networks
2.5 Phone call recordings
When you contact any of our customer services, calls may be registered for training and proving purposes. Calls will be kept for a maximum period of one year. Kindly note that credit card details are not recorded as part of a call.
3- Retention of data:
Unless otherwise specifically indicated in this notice, personal data is retained as long as:
i) there is a legal obligation for it (by way of contract or laws);
ii) when we have a legitimate and reasonable interest in it for proof and compliance with other regulation requirements reasons;
iii) until expiration or withdrawal of consent,
Data in relation to a contractual transaction will be maintained as long as necessary to comply with regulatory requirements such as accounting and tax regulations, and to preserve our defense rights against potential complaints and other legal claims, and at least as long as the longest after sale guarantee granted.
Payment related data will be maintained until after your rights for withdrawal and disputing payment is passed.
Data for marketing communication purposes will be retained as long as the service is on-going, that is until withdrawal of your consent or by reaching the date of expiration of your consent (10 years as previously indicated), whichever earlier. Marketing communication are discretionary actions of Azza Fahmy group, we reserve the right to interrupt or stop such actions whenever it is in the group’s best interest and to correspondently depart from the related data.
4- Your rights with respect to your personal data:
Further to any above-mentioned right, at any time, you can request for the following actions to be taken:
i) Access right: to have access to your data we are processing and to how we are processing it;
ii) Rectification right: for rectification of inaccurate data (update, correct, supplement, replace);
iii) To be forgotten right: for deleting of data from our systems;
iv) Limitation of processing and objecting rights: to object to some of the processing operations or to request for restriction of processing, subject to the governing regulation conditions;
v) Withdrawal of consent right: to withdraw your consent given for any of our services by simple request or opt-out procedure;
vi) Data portability right: to receive your personal data in an easy readable electronic format, or to transfer these data directly to a third party nominated by you.
Azza Fahmy group is obliged by law, and engages to, comply promptly to such requests provided it does not contradict compliance with legal and regulatory requirements and obligations such as accounting and tax regulations, minimum guaranties for preservation of exploitation of legal rights, defence against complaints and other legal claims, and responding to inquiries of public authorities.
Any related request is to be addressed to the following recipients:
5- Right to lodge a complaint with a supervisory authority:
The law grants you the right to file a complaint with respect to our processing of your data with the competent supervisory authority in your jurisdiction. In the UK, complaint should be addressed at the Information Commissioner’s Office (https://ico.org.uk/).
We engage in making our utmost effort and use available technics to ensure protection of your personal data from being illegitimately or fraudulently accessed and/or used.
7- Policy update:
This notice was last updated on the 2/8/2018